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Regulation Equipment

Regulation Equipment

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When a British Army soldier was ordered to attack the enemy on the Western Front he carried a total of 30 kilograms (66 lbs) of equipment. This included a rifle, two mills grenades, 220 rounds of ammunition, a steel helmet, wire cutters, field dressing, entrenching tool, greatcoat, two sandbags, rolled ground sheet, water bottle, haversack, mess tin, towel, shaving kit, extra socks, message book and preserved food rations. The weight of the equipment made it difficult to move very fast across No Man's Land.

We had two days' rations to take, and the 150 rounds of ammunition we always carry. I only took an extra pair of socks, but I wished before I got back that I had taken three extra pairs. We wore our great coats, with full equipment on top of this. Our mack we put on top of the pack. Our water bottle was full and of course we carried our mess tin, also mug and cutlery. The one blanket we were allowed to take was rolled in the ground sheet, and slung like a horse collar round our necks. I carried in addition my pocket primus, and a tin of paraffin, two small tins of Heinz baked beans, vaseline, a tommy's cooker and a tin of re-fill; a pair of gloves, mittens and a muffler. Beside this, we carried our rifle. I wish you could have seen us. We looked like animated old clothes shops.

We whistled and sang the Marseillaise as we tramped. I was loaded with a pack (blanket, waterproof sheet, overcoat, two singlets, two underpants, six handkerchiefs, two towels and several books) a haversack (food, shaving tackle, soap, tooth paste, pocket field dressing materials and odds and ends) entrenching tool and handle for digging in; a large water bottle full of cold tea and my field glasses. And my word it was heavy walking! This is marching order.

Regulation Equipment - History

These days, workers who spend their careers in hazardous environments have access to a wide array of protective apparel and gear to keep them safe and secure. From durable helmets to full-body suits, the range of so-called personal protective equipment (PPE) includes almost everything necessary to ensure worker safety in any kind of worksite. There’s no doubt that, for many occupations, this kind of equipment is absolutely necessary. Today’s working person often faces a number of dangers on a fairly routine basis. Construction sites are fraught with falling objects that could cause fatal injuries. Medical labs contain sensitive biological materials that can induce severe illness. Certain industrial sites may have heat-generating equipment that might cause flammable clothing to catch on fire. The list of potential hazards goes on and on, but the right equipment and apparel, plus a little common sense, is usually enough to prevent injury.

As a supplier of high-grade workplace uniforms since 1932, Prudential Overall Supply is proud of the role it has played—and continues to play—in keeping workers safe from harm. It’s worth bearing in mind, though, that the workers haven’t always been able to access this kind of quality protective gear. The relatively safe working environment that so many benefit from today is the result of a long history of innovations that were engineered by a number of enterprising individuals. Let’s take a look at the history of personal protective equipment by charting the development of certain types of safety gear that we so often take for granted today.

Gloves – Protective gloves have been around for literally thousands of years. In fact, they even get a mention in Homer’s Odyssey, which dates back to the eighth century B.C. this ancient poem includes a brief description of Laertes using gloves to protect his hands from thorns as he works away in his garden. The ancient Greek historian Xenophon also records that the Persians of his time wore gloves to guard their hands from the cold.

Down through the centuries, gloves also came to be a fashion statement of sorts, favored by royalty and other eminent persons. But the common worker used them as well for example, during the Middle Ages, masons would wear sheepskin gloves when handling hazardous tools or materials. Also, leather gloves were commonly used by hunters. These days, there are many types of gloves used on jobsites, all of them with the purpose of protecting the hands from harm of some kind. Prudential sells several types of gloves, including fleece gloves that provide insulation in cold environments at www.shopprudentialuniforms.com.

Hard Hats The idea of using protective gear to keep one's head safe from hard objects is not a new one, as you've probably noticed if you've ever seen a movie depicting warfare in ancient or medieval times. In fact, helmets used for this purpose date back to the 10th century B.C.—and possibly even before. But it wasn't until the 19th century that working people were able to use headgear to keep their skulls safe from danger. Workers on shipbuilding yards hit upon the idea of putting tar on their hats and then setting them out in the sun to dry. This created a tough, durable hat that could protect their heads from the danger posed by falling objects. Around the same time, a New York firefighter named Henry T. Gratacap devised a helmet intended specifically for those in his line of work. Gratacap’s basic design survives largely intact, to this day, in his chosen profession.

In 1898, a California businessman named Edward Dickinson Bullard began selling protective headgear made out of leather. His business did pretty well for years, until the outbreak of World War I gave him an idea to upgrade his leather hats. Bullard’s son was a combatant in WWI when he returned to the U.S. after his tour, he brought with him the steel helmet he had worn as a soldier. This gave Bullard an idea: Why not use a similar type of headgear for workers on construction sites and related environments? The so-called “hard hat” was born.

Today, the hard hat is required in many kinds of worksites. Prudential’s line of products includes snap-on hoods and face masks that are designed to provide additional protection for workers who wear hard hats. It’s also worth pointing out that some types of headgear can do more than merely guard the skull from external objects. So-called “hi-visibility” hats help employees stay safe in environments where sight is often obscured.

Safety Goggles – Welders, lab workers, and other persons who work in hazardous environments can thank safety goggles for protecting their eyesight. It took a while, though, for anyone to come up with the idea for special eyewear to protect workers’ sight from external threats. While eyewear used to magnify poor sight has been around for centuries, the real safety breakthrough came when the African-American inventor Powell Johnson patented (U.S. Pat #234,039) his “eye protectors” in 1880. During the 20th century, demand increased for high-quality eye protection, as individuals in various industries found a need for such gear. This led to further refinements of the basic design.

Nowadays, a good pair of safety goggles is often capable of performing a number of valuable functions: protecting the eyes from UV rays, chemicals, and other hazards, as well as enhancing the sight.

Coveralls – This type of workwear helps ensure the safety of personnel by providing a continuous clothing surface that keeps out many types of hazardous materials, such as molds, and/or minerals, such as asbestos it can also protect the worker against the damaging effects of excessively high (or low) temperatures. This clothing tends to be made from highly dense yet flexible materials that keep hazards out while allowing the worker full freedom of movement.

In the 19th century, firefighters began using special protective clothing intended to shield them from the various dangers associated with the profession. At first, wool uniforms were used to supply a degree of protection from severe heat conditions. For firefighters, progress was slow it wasn’t until the post-WWII years that their uniforms began to be standardized and subject to rigorous safety standards. While the firefighting profession went through these changes, other industries began to see the need for similar protective clothing. This led to the development of protective coveralls, which today come in many varieties to accommodate the needs of different industries.

What is PPE? Prevention and Regulation

The history of protective clothing can be traced as far back as the eighth century B.C. where it has been documented from an ancient Greek poem “Homers Odyssey”. This includes a brief description of Laertes using gloves to protect his hands from thorns as he works away in his garden. The ancient Greek historian Xenophon also records that the Persians of his time wore gloves to guard their hands from the cold.

Down through the centuries, gloves came to become a fashion statement, favoured by royalty and other eminent persons. But the common worker used them as well for example, during the Middle Ages, masons would wear sheepskin gloves when handling hazardous tools or materials. Also, leather gloves were commonly used by hunters. These days, there are many types of gloves used on jobsites, all of them with the purpose of protecting the hands from harm of some kind of nature.

Protecting the head was also paramount, especially in situations of war where helmets of many different types where created for both practical purpose and prominence, over the course of human antiquity. Most early helmets predominantly had military uses, though some may have had more ceremonial than combat-related purposes. The oldest known use of helmets was by Assyrian soldiers in 900 BC, who wore thick leather or bronze helmets to protect the head from blunt object and sword blows and arrow strikes in combat. Helmets used for this purpose date back to the 10th century BC – and possibly even before. But it wasn’t until the 19th century that working people were able to use headgear to keep their skulls safe from danger. Workers on shipbuilding yards hit upon the idea of putting tar on their hats and then setting them out in the sun to dry. This created a tough, durable hat that could protect their heads from the danger posed by falling objects. Around the same time, a New York firefighter named Henry T. Gratacap devised a helmet intended specifically for those in his line of work. Gratacap’s basic design survives largely intact, to this day, in his chosen profession.

Learn more about the different types of safety helmet and their uses:

Edward Dickinson Bullard

In 1898, a California based businessman named Edward Dickinson Bullard began selling protective headgear made out of leather. His business did pretty well for years, until the outbreak of World War I gave him an idea to upgrade his leather hats. Bullard’s son was a combatant in WWI and when he returned to the US after his tour, he brought with him the steel helmet he had worn as a soldier. This gave Bullard an idea: Why not use a similar type of headgear for workers on construction sites and related environments? With this the so-called ‘hard hat’ was born.

What is PPE?

Personal protective equipment (PPE) refers to protective clothing, helmets, goggles, or other garments or equipment designed to protect the wearer’s body from injury or infection. The hazards addressed by protective equipment include physical, electrical, heat, chemicals, biohazards, and airborne particulate matter. Protective equipment may be worn for job-related occupational safety and health purposes, as well as for sports and other recreational activities. ‘Protective clothing’ is applied to traditional categories of clothing, and ‘protective gear’ applies to items such as pads, guards, shields, or masks, along with other items.

The purpose of personal protective equipment is to reduce employee exposure to hazards when engineering controls and administrative controls are not feasible or effective to reduce these risks to acceptable levels. PPE is needed when there are hazards present. PPE has the serious limitation that it does not eliminate the hazard at source and may result in employees being exposed to the hazard if the equipment fails.

Any item of PPE imposes a barrier between the wearer/user and the working environment. This can create additional strains on the wearer impair their ability to carry out their work and create significant levels of discomfort. Any of these can discourage wearers from using PPE correctly, therefore placing them at risk of injury, ill-health or, under extreme circumstances, death. Good ergonomic design can help to minimise these barriers and can therefore help to ensure safe and healthy working conditions through the correct use of PPE.

Good practices

Practices of occupational safety and health can use hazard controls and interventions to mitigate workplace hazards, which pose a threat to the safety and quality of life of workers. The hierarchy of hazard controls provides a policy framework which ranks the types of hazard controls in terms of absolute risk reduction. At the top of the hierarchy are elimination and substitution, which remove the hazard entirely or replace the hazard with a safer alternative. If elimination or substitution measures cannot apply, engineering controls and administrative controls, which seek to design safer mechanisms and coach safer human behaviour, are implemented. Personal protective equipment ranks last on the hierarchy of controls, as the workers are regularly exposed to the hazard, with a barrier of protection. The hierarchy of controls is important in acknowledging that, while personal protective equipment has tremendous utility, it is not the desired mechanism of control in terms of worker safety.

“PPE has the serious limitation that it does not eliminate the hazard at source and may result in employees being exposed to the hazard if the equipment fails”

Examples of PPE include ear muffs, respirators, face masks, hard hats, gloves, aprons and protective eyewear. PPE limits exposure to the harmful effects of a hazard but only if workers wear and use the PPE correctly.

Administrative controls and PPE should only be used:

  • When there are no other practical control measures available (as a last resort)
  • As an interim measure until a more effective way of controlling the risk can be used
  • To supplement higher level control measures (as a back-up)
  • As a last resort, where there are no other practical control measures available
  • To be a short-term measure until a more effective way of controlling the risk can be used
  • Together with other controls measures such as local exhaust ventilation
  • By itself during maintenance activities

“the first question to ask is, can the hazard become eliminated at the source, such as safety in design?”

There may, however, be specific PPE requirements for working with harmful substances or in certain work activities such as asbestos and/or infectious diseases. For any particular hazard, more than one control measure may be needed to address the risk. For example, controlling the risk of exposure to a toxic chemical may require the installation of a ventilation system and establishing a preventive maintenance programme for the ventilation system and the use of warning signs and the use of PPE. If you are protecting against exposure to a substance such as a hazardous chemical or a biological substance, consider how the substance can enter the body. For example, where a chemical can be absorbed through the lungs and skin, skin protection as well as respiratory protection may be required.

Having a safe system of work in place is essential, and highlights the business case for safety. The investment in work, health and safety should take into consideration a strategic one. The Hierarchy of Risk Control uses a method of top down management. By prioritising higher risk control methods related specifically to the potential hazards, this makes for a safer workplace and is the investment in safety required for denoting a situation in which each party benefits in some way better productivity and safer workers.

So in the future, the first question to ask is: “Can the hazard become eliminated at the source, such as safety in design?” If so, problem solved. If not, start working your way down the list, and qualify your answer by ensuring appropriate controls have been identified. Senior management and any workers who will be affected by the changes should be consulted and their input sought. This will minimise oversight and increase support and adoption of the changes and may also lead to increased worker satisfaction and ultimately result in achieving a win win situation for all.

Rule History

In 1990, the Oil Pollution Act amended the Clean Water Act to require some oil storage facilities to prepare Facility Response Plans. On July 1, 1994, EPA finalized the revisions that direct facility owners or operators to prepare and submit plans for responding to a worst-case discharge of oil (Subpart D).

Following the Floreffe, Pennsylvania oil spill in 1988, EPA formed the SPCC Task Force to examine federal regulations governing oil spills from aboveground storage tanks. The SPCC Task Force recommended that EPA:

  • clarify certain provisions in the Oil Pollution Prevention Regulation,
  • establish additional technical requirements for regulated facilities, and
  • require the preparation of facility-specific response plans.

In response to the Task Force recommendation, EPA proposed revisions to the Oil Pollution Prevention Regulation in the 1990s and finalized the amendments in 2002. EPA has since amended the SPCC requirements of the Oil Pollution Prevention Regulation to extend compliance dates and clarify and/or tailor specific regulatory requirements.

A History of Medical Device Regulation & Oversight in the United States

The Food and Drug Administration (FDA) is the oldest comprehensive consumer protection agency in the United States. The FDA’s oversight of food and drugs began in 1906 when President Theodore Roosevelt signed the Pure Food and Drugs Act. Since then, Congress has expanded the FDA’s role in protecting and promoting the development of human and veterinary drugs, biological products, medical devices and radiation-emitting products, human and animal food, and cosmetics.

In the 1960s and 1970s, Congress responded to the public’s desire for more oversight over medical devices by passing the Medical Device Amendments to the Federal Food, Drug, and Cosmetic Act. In 1982, the organizational units at the FDA that regulated medical devices and radiation-emitting products merged to form the Center for Devices and Radiological Health (CDRH).

The chronology below highlights milestones in the history of medical device legislation in the United States. For additional details, please see the text of the individual Acts.

References and Further Reading

Aldrich, Mark. Safety First: Technology, Labor and Business in the Building of Work Safety, 1870-1939. Baltimore: Johns Hopkins University Press, 1997.

Aldrich, Mark. “Preventing ‘The Needless Peril of the Coal Mine’: the Bureau of Mines and the Campaign Against Coal Mine Explosions, 1910-1940.” Technology and Culture 36, no. 3 (1995): 483-518.

Aldrich, Mark. “The Peril of the Broken Rail: the Carriers, the Steel Companies, and Rail Technology, 1900-1945.” Technology and Culture 40, no. 2 (1999): 263-291

Aldrich, Mark. “Train Wrecks to Typhoid Fever: The Development of Railroad Medicine Organizations, 1850 -World War I.” Bulletin of the History of Medicine, 75, no. 2 (Summer 2001): 254-89.

Derickson Alan. “Participative Regulation of Hazardous Working Conditions: Safety Committees of the United Mine Workers of America,” Labor Studies Journal 18, no. 2 (1993): 25-38.

Dix, Keith. Work Relations in the Coal Industry: The Hand Loading Era. Morgantown: University of West Virginia Press, 1977. The best discussion of coalmine work for this period.

Dix, Keith. What’s a Coal Miner to Do? Pittsburgh: University of Pittsburgh Press, 1988. The best discussion of coal mine labor during the era of mechanization.

Fairris, David. “From Exit to Voice in Shopfloor Governance: The Case of Company Unions.” Business History Review 69, no. 4 (1995): 494-529.

Fairris, David. “Institutional Change in Shopfloor Governance and the Trajectory of Postwar Injury Rates in U.S. Manufacturing, 1946-1970.” Industrial and Labor Relations Review 51, no. 2 (1998): 187-203.

Fishback, Price. Soft Coal Hard Choices: The Economic Welfare of Bituminous Coal Miners, 1890-1930. New York: Oxford University Press, 1992. The best economic analysis of the labor market for coalmine workers.

Fishback, Price and Shawn Kantor. A Prelude to the Welfare State: The Origins of Workers’ Compensation. Chicago: University of Chicago Press, 2000. The best discussions of how employers’ liability rules worked.

Graebner, William. Coal Mining Safety in the Progressive Period. Lexington: University of Kentucky Press, 1976.

Great Britain Board of Trade. General Report upon the Accidents that Have Occurred on Railways of the United Kingdom during the Year 1901. London, HMSO, 1902.

Great Britain Home Office Chief Inspector of Mines. General Report with Statistics for 1914, Part I. London: HMSO, 1915.

Hounshell, David. From the American System to Mass Production, 1800-1932: The Development of Manufacturing Technology in the United States. Baltimore: Johns Hopkins University Press, 1984.

Humphrey, H. B. “Historical Summary of Coal-Mine Explosions in the United States — 1810-1958.” United States Bureau of Mines Bulletin 586 (1960).

Kirkland, Edward. Men, Cities, and Transportation. 2 vols. Cambridge: Harvard University Press, 1948, Discusses railroad regulation and safety in New England.

Lankton, Larry. Cradle to Grave: Life, Work, and Death in Michigan Copper Mines. New York: Oxford University Press, 1991.

Licht, Walter. Working for the Railroad. Princeton: Princeton University Press, 1983.

Long, Priscilla. Where the Sun Never Shines. New York: Paragon, 1989. Covers coal mine safety at the end of the nineteenth century.

Mendeloff, John. Regulating Safety: An Economic and Political Analysis of Occupational Safety and Health Policy. Cambridge: MIT Press, 1979. An accessible modern discussion of safety under OSHA.

National Academy of Sciences. Toward Safer Underground Coal Mines. Washington, DC: NAS, 1982.

Rogers, Donald. “From Common Law to Factory Laws: The Transformation of Workplace Safety Law in Wisconsin before Progressivism.” American Journal of Legal History (1995): 177-213.

Root, Norman and Daley, Judy. “Are Women Safer Workers? A New Look at the Data.” Monthly Labor Review 103, no. 9 (1980): 3-10.

Rosenberg, Nathan. Technology and American Economic Growth. New York: Harper and Row, 1972. Analyzes the forces shaping American technology.

Rosner, David and Gerald Markowity, editors. Dying for Work. Blomington: Indiana University Press, 1987.

Shaw, Robert. Down Brakes: A History of Railroad Accidents, Safety Precautions, and Operating Practices in the United States of America. London: P. R. Macmillan. 1961.

Trachenberg, Alexander. The History of Legislation for the Protection of Coal Miners in Pennsylvania, 1824 – 1915. New York: International Publishers. 1942.

U.S. Department of Commerce, Bureau of the Census. Historical Statistics of the United States, Colonial Times to 1970. Washington, DC, 1975.

Usselman, Steven. “Air Brakes for Freight Trains: Technological Innovation in the American Railroad Industry, 1869-1900.” Business History Review 58 (1984): 30-50.

Viscusi, W. Kip. Risk By Choice: Regulating Health and Safety in the Workplace. Cambridge: Harvard University Press, 1983. The most readable treatment of modern safety issues by a leading scholar.

Wallace, Anthony. Saint Clair. New York: Alfred A. Knopf, 1987. Provides a superb discussion of early anthracite mining and safety.

Whaples, Robert and David Buffum. “Fraternalism, Paternalism, the Family and the Market: Insurance a Century Ago.” Social Science History 15 (1991): 97-122.

White, John. The American Railroad Freight Car. Baltimore: Johns Hopkins University Press, 1993. The definitive history of freight car technology.

Whiteside, James. Regulating Danger: The Struggle for Mine Safety in the Rocky Mountain Coal Industry. Lincoln: University of Nebraska Press, 1990.

Wokutch, Richard. Worker Protection Japanese Style: Occupational Safety and Health in the Auto Industry. Ithaca, NY: ILR, 1992

Worrall, John, editor. Safety and the Work Force: Incentives and Disincentives in Workers’ Compensation. Ithaca, NY: ILR Press, 1983.

1 Injuries or fatalities are expressed as rates. For example, if ten workers are injured out of 450 workers during a year, the rate would be .006666. For readability it might be expressed as 6.67 per thousand or 666.7 per hundred thousand workers. Rates may also be expressed per million workhours. Thus if the average work year is 2000 hours, ten injuries in 450 workers results in [10/450�]x1,000,000 = 11.1 injuries per million hours worked.

2 For statistics on work injuries from 1922-1970 see U.S. Department of Commerce, Historical Statistics, Series 1029-1036. For earlier data are in Aldrich, Safety First, Appendix 1-3.

3 Hounshell, American System. Rosenberg, Technology,. Aldrich, Safety First.

4 On the workings of the employers’ liability system see Fishback and Kantor, A Prelude, chapter 2

5 Dix, Work Relations, and his What’s a Coal Miner to Do? Wallace, Saint Clair, is a superb discussion of early anthracite mining and safety. Long, Where the Sun, Fishback, Soft Coal, chapters 1, 2, and 7. Humphrey, “Historical Summary.” Aldrich, Safety First, chapter 2.

6 Aldrich, Safety First chapter 1.

7 Aldrich, Safety First chapter 3

8 Fishback and Kantor, A Prelude, chapter 3, discusses higher pay for risky jobs as well as worker savings and accident insurance See also Whaples and Buffum, “Fraternalism, Paternalism.” Aldrich, ” Train Wrecks to Typhoid Fever.”

9 Kirkland, Men, Cities. Trachenberg, The History of Legislation Whiteside, Regulating Danger. An early discussion of factory legislation is in Susan Kingsbury, ed.,xxxxx. Rogers,” From Common Law.”

10 On the evolution of freight car technology see White, American Railroad Freight Car, Usselman “Air Brakes for Freight trains,” and Aldrich, Safety First, chapter 1. Shaw, Down Brakes, discusses causes of train accidents.

11 Details of these regulations may be found in Aldrich, Safety First, chapter 5.

12 Graebner, Coal-Mining Safety, Aldrich, “‘The Needless Peril.”

13 On the origins of these laws see Fishback and Kantor, A Prelude, and the sources cited therein.

14 For assessments of the impact of early compensation laws see Aldrich, Safety First, chapter 5 and Fishback and Kantor, A Prelude, chapter 3. Compensation in the modern economy is discussed in Worrall, Safety and the Work Force. Government and other scientific work that promoted safety on railroads and in coal mining are discussed in Aldrich, “‘The Needless Peril’,” and “The Broken Rail.”

15 Farris, “From Exit to Voice.”

16 Aldrich, “‘Needless Peril,” and Humphrey

17 Derickson, “Participative Regulation” and Fairris, “Institutional Change,” also emphasize the role of union and shop floor issues in shaping safety during these years. Much of the modern literature on safety is highly quantitative. For readable discussions see Mendeloff, Regulating Safety (Cambridge: MIT Press, 1979), and

The object of the game

The opposing team must try to prevent the ball from bouncing before returning the ball. The games are played in the best of 3 or 5 sets, and the team with the most sets at the end of the game wins.

In Volleyball rules and regulations, Each team has 6 players on the field at the same time. Substitutes can be used throughout the game. There are no professional mixed gender bands.

Each player occupies a position in the attack zone (next to the grid) or in the defensive zone (behind the court). Three players are in each zone and rotate clockwise after each point.

The ground has a rectangular shape and has dimensions of 18m x 9m. Running through the pitch is a net with a height of 2.43 m. The ball with a diameter should have of 8 inches and a mass between 9 and 10 ounces.

Around the contour of the field, there is an area outside the field, and if the ball was to be reflected in these sections, then the point would be awarded to the opposing team.

Each team receives up to two-time limits per set for 30 seconds each. After each set, the number of timeout exceedances is restored to two, regardless of how many of them have been previously used.

Sticks, Clubs and Bats

Alexander Rutherford is credited with the creation of the first hockey stick, carved in 1852 near the town of Lindsay, Ontario. Sticks originally had flat blades but between 1957 and 1980, curved blades became more common.

Before the 16th century, golfers often made their own clubs themselves, usually out of wood. King James IV of England had William Mayne make a set of clubs for him, as Mayne's clubs were designed for longer shots, medium shots and shots close to the hole. This is the origin of the golf club set, according to the GolfClubRevue website. In the 1800s, it became easier to make iron clubs as they could be mass produced. Today golf clubs feature technologically advanced drivers, irons and putters.

Early baseball bats were quite heavy and had a thicker handle than the bats used today. In 1865, it was agreed upon that bats should be made from ash or hickory. Three years later, regulations were introduced that a bat could not exceed 42 inches in length. The bat's maximum thickness, 2 and 3/4 inches, was decided upon in 1895 and is still the rule in the MLB today.

100 Years of Respiratory Protection History

In 1919, the U.S. Bureau of Mines (USBM) initiated the first respirator certification program. Several months later, on January 15, 1920, this federal body certified the first respirator. To recognize the important milestones of the past 100 years, this webpage documents a general historical overview of respiratory protection research and the evolution of the certification program as undertaken by the U.S. federal government.

Respiratory Protection History Prior to the 1800s

Pliny the Elder, photo courtesy of Shutterstock

Around the world, scientific minds recognized the need for respiratory protection long before the U.S. Bureau of Mines. The history of respiratory protection traces back as far as Pliny the Elder (23-79 AD), a Roman philosopher and naturalist, who made use of loose animal bladder skins to filter dust from being inhaled while crushing cinnabar, which is a toxic, mercuric sulfide mineral used at the time for pigmentation in decorations. Many centuries later, Leonardo da Vinci (1452-1519) recommended the use of wet cloths over the mouth and nose as a form of protection against inhaling harmful agents (Spelce et al., &ldquoHistory,&rdquo 2018 Cohen and Birkner, 2012).

Further scientific inquiry and discovery led to the use of early atmosphere-supplying respirators. While ancient divers used hoses and tubes for supplied air, seventeenth century scientists added bellows to these devices as a way of providing positive pressure breathing. Although science has made advancements over time, the need for proper respiratory protection became increasingly apparent. In the 1700s, Bernadino Ramazzini, known as the father of occupational medicine, described the inadequacy of respiratory protection against the hazards of arsenic, gypsum, lime, tobacco, and silica (Spelce et al., &ldquoHistory,&rdquo 2018 Cohen and Birkner, 2012).

While these scientific discoveries and advancements to respiratory protection were pivotal, the most important date for respiratory protection was still to come.

Nealy Smoke Mask from The National Fireman's Journal December 8, 1877

The 18 th and 19 th centuries achieved the development of what we would recognize today as respirators, far surpassing the use of animal bladders and wet cloths. In 1827, the Scottish botanist Robert Brown discovered the phenomenon known as the Brownian movement &ndash the theory that collisions of rapidly moving gas molecules causes the random bouncing motion of extremely small particles. Understanding the behavior of small particles, the properties of filter media and their interactions led to the first particulate respirator. In the mid-1800s, German scientists conducted studies with industrial dust and bacteria and their relationship with respiratory health. In 1877, the English invented and patented the Nealy Smoke Mask. The Nealy Smoke Mask used a series of water-saturated sponges and a bag of water attached to a neck strap. The wearer could squeeze the bag of water to re-saturate the sponges to filter out some of the smoke. (Coffey, 2016 Cohen and Birkner, 2012 Kloos, 1963).

On July 1, 1910, the U.S. Department of the Interior established the United States Bureau of Mines (USBM). The USBM worked to address the high fatality rate of mineworkers. In 1919, the USBM initiated the first respirator certification program in the United States. In 1920, MSA Safety Company manufactured the Gibbs respirator. This closed-circuit self-contained breathing apparatus (SCBA) operated on compressed oxygen and a soda lime scrubber to remove carbon dioxide. (Spelce et al., 2017). According to MSA Safety Company, industries, fire departments, and health departments were the first to utilize the Gibbs Breathing Apparatus (WebApps.MSANet.com). The U.S. Navy requested a respirator comparable to those used for emergency escape purposes for mineworkers, leading to the invention of the Gibbs breathing apparatus, named for United States Bureau of Mines engineer and inventor W.E. Gibbs. Gibbs also created a respirator specifically for aviators (Spelce, et al., 2017).

World War I presented a new kind of threat to soldiers &ndash chemical warfare gases, such as chlorine, phosgene, and mustard gas. The U.S. War Department asked the USBM to develop gas mask standards. Military equipment at the time did not account for protective masks or respirators. Combat equipment did not include respirators until World War II (Caretti, 2018). As a result, chemical warfare in WWI accounted for 1.3 million casualties and approximately 90,000 fatalities. This amounted to about 30% of all casualties during the war (Fitzgerald, 2008).

World War I respiratory protection, photo courtesy of Shutterstock

Additionally, WWI troops from all over the world helped a new influenza virus spread. The lack of vaccines and respiratory protection contributed to high fatalities from the flu virus. The U.S. reported the first flu symptoms in March 1918. In October of 1918 alone, the flu virus killed 195,000 Americans resulting in the San Francisco Board of Health recommending the use of masks in public spaces. The pandemic flu began to decline in early 1919. The flu caused approximately 50 million deaths across the world, including 675,000 in the United States (&ldquo1918 Pandemic,&rdquo 2018). The spread of the pandemic flu at this time displayed the need of additional respiratory protection and research needed in healthcare settings.

While the flu pandemic exhibited a need for healthcare respiratory protection, researchers at the time still largely focused on the respiratory protection of mining. On March 5, 1919, the USBM produced Schedule 13, &ldquoProcedure for Establishing a List of Permissible Self-Contained Oxygen Breathing Apparatus.&rdquo Schedule 13 set the first set of regulations for human testing of protection of self-contained breath apparatus respirators and certification thereof (Kyriazi, 1999). Finally, on January 15, 1920 the USBM certified the first respirator, the Gibbs breathing apparatus. (Spelce et al., &ldquoHistory,&rdquo 2018 Cohen and Birkner, 2012). The Gibbs breathing apparatus, originally designed for mine work, became the first approved respirator for industrial work. (Spelce, et al., 2017).

Gibb&rsquos Breathing Apparatus

During World War I, the U.S. government sought improvements for respiratory protection across several industries as well as the military. The passing of the Overman Act of May 20, 1918 by President Wilson gave authority for the Army to lead the research efforts in respiratory protection in order to engage in chemical warfare and defense. However, this delegation of research power was short-lived, and the USBM regained the primary task of mine safety research. (Spelce, et al., 2017).

The USBM developed Schedule 14 shortly after for the certification of military-use gas masks. Over time, the USBM altered Schedule 14, &ldquoProcedure for Establishing a List of Permissible Gas Masks,&rdquo several times. Initial modifications to it included acknowledgement of the 1941 USBM &ldquoFacepiece Tightness Test&rdquo which tested the detectable leakages and freedom of movement of the user (Spelce, et al., &ldquoHistory&rdquo (Cont.), 2018).

Because of the horrific casualties of WWI from chemical warfare, armed forces on both sides of the battlefield refrained from using chemical agents during WWII. Both sides shared the paranoia that the enemy had more harmful chemical warfare agents (Chauhan, 2008). As the world entered World War II, the U.S. Navy&rsquos use of asbestos increased for insulation purposes for pipes in naval vessels. It was not until 1939 that a Medical Officer for the U.S. Navy recognized the need for crew to wear respirators when cutting and wetting amosite and other asbestos containing insulation. Later, as the U.S. entered World War II, Fleischer et al. released a study acknowledging the dangers and risks of dust exposures in asbestos insulation manufacturing. However, even after the publication of the Fleischer et al. study in 1946, the U.S. Navy continued to use asbestos with the additional warning that &ldquoexposure to asbestos dust is a hazard which cannot be overlooked in maintaining an effective occupational-hygiene program.&rdquo The Navy continued to recommend confinement of pipe covering operations, and the use of respirators and ventilation (Barlow et al., 2017).

1930s Mask, photo courtesy of Caretti

In the early 1930s, the Hawk&rsquos Nest Tunnel disaster occurred in West Virginia. The estimated death toll, one of the worst in American industrial history, ranges from roughly 700-1,000 deaths of the 3,000 who worked underground. The tragedy of this disaster expedited the publication of the USBM&rsquos first approval of dust/fume/mist respirator approval standards in 30 CFR Part 14, Schedule 21 (USBM 1934). &ldquoThe USBM had already developed standards for and approved oxygen breathing apparatus (1919), gas mask respirators (1919), and hose mask respirators (1927). By 1937, the Bureau expanded its schedule for testing hose masks to include a variety of supplied-air respirators including Type CE abrasive blasting respirator&rdquo (Spelce, et al., 2019). Schedule 21 describes several types of respirators, including Type A, B, C, combinations of A-C, and D (Spelce, et al., 2019). The original Schedule 21 from 1934 included the following requirements:

  • Exhalation valves were required, and inhalation valves were optional
  • Added Pressure-Tightness Tests to assess the fitting characteristics of the respirator
  • Revised the Direct Leakage and Man Test (coal dust test) by eliminating work exercises
  • The high concentration silica dust defined the test period as one 90-minute test, not three 30-minute test periods
  • Eliminated the low concentration Silica Dust Test
  • Water Silica Mist and Chromic Acid Mist Tests defined the sampling period after 156 minutes and after 312 minutes, respectively
  • Added a Lead Dust Test
  • Eliminated the Lead Paint Test

Revisions to Schedule 21 expanded in 1955 under 30 CFR 14 to include the approval respirators with single use filters and reusable filters. Among these, there are two classes of respirators, including approval for protection against Pneumoconiosis and approval against dust that were not more toxic than lead. These approvals expanded to also included protection against lead fumes, silica, and chromic acid mists (Spelce, et al., 2019).

The USBM began to set stricter regulations on respirators during WWII. It established &ldquocertain basic requirements applicable to all types of respiratory equipment. These requirements are as follows: (1) They must give adequate protection (2) they must be reasonably comfortable and physically convenient to wear (3) they must provide an acceptable period of protection and (4) they must be constructed of durable materials. (IC 7130, August 1940, page 5)&rdquo (Spelce et al., 2018 D&rsquoAlessandro, 2018). The regulation of respiratory protection permitted the standardization of higher quality respiratory protection.

After WWII and the use of chemical gas in warfare, researchers continued their work on improving respiratory protection for soldiers. The events of World War II and the boom of industry on the home front exhibited a need for improved respiratory protection in industry. Americans on the home front went to work on the production lines to aid the war effort, ushering in a booming era of industry and manufacturing. However, those workers inhaled high amounts of asbestos due to poorly regulated working conditions. Early accounts from turn of the century industrial hygienists documented the dangers of airborne asbestos in working environments, but it was not until the mid-1950s that prolonged exposure to asbestos caused widespread concern. Research efforts still did not fully serve this need until even later, in the 1960s and 1970s. &ldquoWith the introduction of the membrane filter sampling method in the late 1960s and early 1970s, asbestos sampling and exposure assessment capabilities advanced to a degree which allowed industrial hygienists to more precisely characterize the exposure&ndashresponse relationship&rdquo (Barlow et al., 2017).

Non-combatant mask, circa 1940, photo courtesy of Caretti

Researchers performed tests on respirators to measure protection, but their levels of protection were unregulated. There was not yet a system in place to set a threshold standard of protection nor any regulatory body in the manufacturing of respirators. The respirators used in different settings, such as in construction or commercial farming, lacked regulation to ensure necessary protection against the airborne hazards in these types of settings.

Further, Schedule 21B in 1965 expanded. These changes include (1) extend certification of approval to respirators designed to protect against dusts, fumes, and mists that are significantly more toxic than lead (2) permit certification of combinations of dispersoid-filter and other types of respirators (3) revise current tests to realize accuracy and speed of testing and (4) revise the fees for inspection and testing (USBM, 1964) (Spelce, et al., 2019). This provided further regulation and protection for industrial workers&rsquo respiratory health.

&ldquoThe use of respirators continued unregulated until the Federal Coal Mine Health and Safety Act was enacted in 1969, resulting in regulations governing the certification and use of respirators in the mining industry. The Occupational Safety and Health Act, which established the Occupational Safety and Health Administration (OSHA) and the National Institute of Occupational Safety and Health (NIOSH), was promulgated in 1970&rdquo (Cohen and Birkner, 2012).

According to the Occupational Safety and Health Act of 1970, &ldquoThe Congress finds that personal injuries and illnesses arising out of work situations impose a substantial burden upon, and are a hindrance to, interstate commerce in terms of lost production, wage loss, medical expenses, and disability compensation payments&rdquo (91 st Congress, 1970). Further, the OSH Act of 1970 acknowledges a need for regulation in the safety and health of working citizens to preserve &ldquohuman resources.&rdquo The document sets standards for work places to maintain as well as formulate a regulatory body to oversee the adherence to these standards. The OSH Act not only sets standards to protect workers from physical injury and disease, but also acknowledges the necessity to protect workers from psychological harm in the workplace, such as anxiety linked to physical injury risk at work.

The OSH Act also established the National Institute for Occupational Safety and Health (NIOSH) as a research body focused on the health, safety, and empowerment of workers to create safe and healthy workplaces (NIOSH, &ldquoAbout&rdquo). OSHA and NIOSH continue to be important organizations that assist in safety recommendation and regulation in the workplace, in the area of respiratory protection as well as other areas of personal protective equipment.

&ldquoCongress created the Occupational Safety and Health Administration (OSHA) in 1970, and gave it the responsibility for promulgating standards to protect the health and safety of American workers. On February 9, 1979, 29 CFR 1910.134 gained recognition as applicable to the construction industry (44 FR 8577). Until the adoption of these standards by OSHA, most guidance on respiratory protective devices use in hazardous environments was advisory rather than mandatory&rdquo (Department of Labor, 1998). OSHA reprinted, without change of text, 29 CFR Part 1926 with the General Industry Occupational Safety and Health Standards in 29 CFR part 1910. This has since become a set of OSHA regulations (&ldquoEditorial Note,&rdquo 1978).

In 1994, the U.S. Centers for Disease Control and Prevention (CDC) released a Morbidity and Mortality Weekly Report entitled &ldquoGuidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Facilities, 1994.&rdquo This document revises the 1990 tuberculosis (TB) guidelines in response to an outbreak in 1991 and studies from 1985 that show a multi-drug resistance to the bacterium that causes TB. These guidelines emphasize importance of healthcare professionals&rsquo proper use of personal protective equipment (PPE), specifically respiratory protection. Areas of emphasis for respiratory protection include ventilation, donning, use, and doffing. Finally, the guidelines address the need to maintain a full respiratory protection program within healthcare settings, ensuring all healthcare workers train in proper PPE use. This is of particular importance for healthcare workers that move from department to department, such as therapists, dieticians, maintenance, interns, etc.

As respiratory protection became mandatory, the importance of a tight and proper respirator fit increased. In 1995, OSHA revised the certification regulations for fit testing. This led to further research in 1996 regarding exposure in the workplace, causing researchers to use simulated workplace protection factors and exposure simulations (Cohen and Birkner, 2012 Department of Labor, 1998).

&ldquoOn 10 July 1995, the respirator certification regulation, 30 CFR 11, was replaced by 42 CFR 84 (NIOSH, 1995). The primary regulatory changes introduced by 42 CFR 84 are associated with a new approval concept, performance requirements for particulate respirator filters, and instrumentation technology. 42 CFR 84 updated filter requirements and tests to provide an assessment of the effectiveness of the filter based upon its efficiency to remove particulates of the most penetrating size from the ambient air regardless of the particulate composition and toxicity (NIOSH, 1994). The approval philosophy for filters changed from minimum requirements considered safe to breathe for various types of dust/fume/mist respirators to acceptable filter efficiency levels against laboratory generated aerosols with particles of the most penetrating size&rdquo (Spelce, et al., 2019).

The OSHA respiratory protection standard, 29 CFR 1910.134, published on January 8, 1998, replaced the agency&rsquos original standard promulgated in 1972. The rule standardized regulations for respirator use in all industries, including maritime, construction, and general industry. However, this did not include updates for the respiratory protection of the healthcare industry, which at this time still functioned under 29 CFR 1910.134 regulations. While this new development did not include the use of respirators in the healthcare setting, it did effectively progress industry, manufacturing, and construction towards a more healthy and safe work environment.

The necessity for respiratory protection in the healthcare setting came to the forefront of concern with the outbreak of tuberculosis in the 1990s. According to the TB Respiratory Protection Program in Health Care Facilities: Administrator&rsquos Guide, &ldquoThe use of respirators in the health care setting is a relatively new but important step forward in the efforts to prevent the transmission of tuberculosis (TB). Air-purifying respirators provide a barrier to prevent health care workers from inhaling Mycobacterium tuberculosis. The level of protection a respirator provides is determined by the efficiency of the filter material and how well the facepiece fits or seals to the health care worker&rsquos face. A number of studies have shown that surgical masks will not provide adequate protection in filtering out the TB organism. Additionally, surgical masks are not respirators and therefore, are not NIOSH-certified and do not satisfy OSHA requirements for respiratory protection&rdquo(1999).

In 2001, Congress requested the creation of a division within NIOSH to focus on the improvement and research of PPE and personal protective technologies (PPT). This division, the National Personal Protective Technology Laboratory (NPPTL) conducts scientific research, develops guidance and authoritative recommendations, disseminates information, and responds to requests for workplace health hazard evaluations.

The focus for respiratory protection research shifted drastically in the early 2000s when national tragedy struck. On September 11, 2001, terrorist attacks in New York City, Shanksville, PA, and Washington D.C. led to first responders in these cities, as well as nationally, to jump into action. The employees of NIOSH NPPTL also mobilized. According to NIOSH NPPTL employee Robert Stein,

&ldquoIf anyone ever doubted the potential for impact on a vast scale, those doubts should have been firmly dispelled the morning of September 11, 2001. I was sitting at my desk that was in building 02 at the time when I got a phone call from one of my colleagues who was off site that day. He said, &ldquoThey are flying planes into the World Trade Center.&rdquo I had already heard the news that an airplane had hit one of the World Trade Center towers, but his was the first voice to identify and call it out as an intentional act. Things started to develop rapidly after that. The personnel at the newly formed lab gathered to develop response plans. Response planning quickly evolved into planning for communication contingencies as we got word that government sites would be evacuated. Obedient to the directions to leave the work site, several of us mustered at the nearby home of one of our colleagues to finish up with our what-if&rsquos and how-to-get-in-touch-with&rsquos. It was an eerie ride home, very confusing to the senses travelling under the beautiful blue skies of a perfect late summer day, but with such serious and unknown threats seemingly looming everywhere.

Even while there was still a ban on commercial flights, NPPTL sent two individuals to the World Trade Center site to help with respiratory protection issues as they were occurring. Not only were they able to provide immediate assistance at the World Trade Center site, but the first-hand experience they gained observing the difficulties encountered trying to provide respiratory protection to such a large number of first responders, recovery workers, law enforcement personnel, and other workers involved in the response helped to shape technical and policy decisions for months and years afterwards. The entire lab dedicated long hours in order to complete new statements of standard for respirator types with protections appropriate to protect first-responders involved in terrorist incidents, and then approve respirators so those new standards would actually result in providing appropriate respiratory protection for those workers.&rdquo

Following the terrorist attacks on September 11, 2001, the PPE used by first responders became a top priority for NIOSH, as it emphasized the PPE needed to protect those risking their own lives in order to save lives. In the weeks after September 11, the New York City Fire Department&rsquos Bureau of Health Services (FDNY-BHS) and NIOSH launched a collaborative study. This study researched the effectiveness of personal protective equipment, including respiratory protection, and the occupational hazards and exposures of these first responders. The results indicated that many firefighters did not use adequate respiratory protection during the first week of the rescue/recovery operation (MMWR, 2002).

First Responders using inconsistent respiratory protection practices, photo courtesy of Shutterstock

A study researched seven first responders to the attacks in New York on September 11 and their exposure to the dust at Ground Zero on September 11 or September 12. All were non-smokers or had only smoked in their distant past. The results of the study showed that all seven first responders developed some form of lung disease after their exposure to the dust at Ground Zero (Wu, et al., 2010).

Research suggests the rate of respiratory illness was so high due to a lack in use of respiratory protection. According to firsthand accounts by P.J. Lioy and M. Gochfeld in their 2002 article &ldquoLessons Learned on Environmental, Occupational, and Residential Exposures from the Attack on the World Trade Center,&rdquo an alarmingly low number of individuals were using respiratory protection in the field at Ground Zero, and many that had respiratory protection were not wearing it (Crane et al., 2012).

The work to improve respiratory protection and subsequent guidance on use of respiratory protection has continued well after 2001. In 2005, NIOSH released its &ldquoInterim Guidance on the Use of Chemical, Biological, Radiological, and Nuclear (CBRN) Full Facepiece, Air-Purifying Respirators/Gas Masks Certified under 42 CFR Part 84.&rdquo According to NIOSH NPPTL employee, Jeff Peterson, &ldquoI would certainly say that one of the biggest accomplishments in the field of respiratory protection is the development of the voluntary NIOSH CBRN requirements.&rdquo

The CBRN requirements answered the need of emergency responders to maintain knowledge of PPE in a time of increased global terrorism. This interim guidance document provided guidelines for the selection and use of NIOSH-approved full facepiece, tight fitting, non-powered, air-purifying respirators (APR) for protection against quantified CBRN agents.

Following September of 2001, NIOSH and The RAND Corporation developed multiple volume reports dedicated to protecting emergency responders (Szalajda, 2008). NIOSH also developed three CBRN standards. The first requires that self-contained breathing apparatus (SCBA) meet CBRN protection standards because it &ldquois used where the respiratory threat level is unknown or known to be immediately dangerous to life and health (IDLH)&rdquo (Szalajda, 2008).

Secondly, NIOSH developed a standard for a full-facepiece, air-purifying respirator. &ldquoThe CBRN APR full-facepiece respirator is widely used by multiple responder groups. It provides a lower level of protection than the SCBA and its use is generally allowed once conditions are understood and exposures are determined to be at levels below those considered to be IDLH&rdquo (Szalajda, 2008).

The third priority was that air-purifying and self-contained escape respirators meet CBRN standards. This enabled a more general workforce, rather than those solely focused on first responders, to use PPE safely in a CBRN terrorist incident. As addressed by Deputy Director Jon Szalajda, NIOSH NPPTL &ldquocontinues to develop criteria for additional types of respirators in response to responders&rsquo needs for appropriate respiratory protection against the anticipated hazards faced in performing rescue and recovery operations resulting from viable terrorist threats, as well as HAZMAT incidents&rdquo (Szalajda, 2008).

Nurse demonstrating the donning of PPE worn by healthcare providers when treating an Ebola patient in a medical intensive care unit (ICU), photo courtesy of the CDC

In 2015, the American National Standard Institute (ANSI) standard Z88.2 updated the standard practice for respiratory protection. The Z88 Committee established the standard in 1969, with revisions in 1989 and 1992. The Z88.2 standard &ldquosets forth minimally accepted practices for occupational respirator use provides information and guidance on the proper selection, use and maintenance of respirators, and contains requirements for establishing, implementing and evaluating respirator programs. The standard covers the use of respirators to protect persons against the inhalation of harmful air contaminants and against oxygen-deficient atmospheres in the workplace&rdquo (ANZ88.2-2015, 1.1).

From 2014-2016, a global epidemic of the Ebola virus disease spread to the United States. During this time, proper PPE use in healthcare settings became a paramount concern, as the highly contagious virus spreads from contact with blood and other bodily fluids. Because of the virus&rsquo highly contagious nature, the CDC recommended the use of a NIOSH-approved N95 respirator, or higher level of particulate filtration, or a powered air-purifying (PAPR) when caring for a Person Under Investigation (PUI) for the Ebola virus disease or a person with a confirmed case of the virus. Further, the CDC released guidelines for the disposal, cleaning, and disinfection based on the type of respirator worn by a healthcare worker when treating an Ebola patient. (Frequently Asked Questions, Ebola, 2018).

In 2019, &ldquoNIOSH NPPTL continues to provide national and world leadership in respirator approval, research, and standards development to support the workers who rely on respiratory protection,&rdquo states NPPTL Director, Dr. Maryann D&rsquoAlessandro. Such research includes understanding respirator comfort, fit, and usability stockpiling of respirators and rapid respiratory protection training in healthcare settings.


1. &thinspSee generally Nighttime Glare and Driving Performance, Report to Congress, p. ii (2007), National Highway Traffic Safety Administration, Department of Transportation [hereinafter &ldquo2007 Report to Congress&rdquo].

2. &thinsp2007 Report to Congress, pp. iv, 11-14. See also, e.g., John D. Bullough et al. 2003. An Investigation of Headlamp Glare: Intensity, Spectrum and Size, DOT HS 809 672. Washington, DC: U.S. Department of Transportation, National Highway Traffic Safety Administration [hereinafter &ldquoInvestigation of Headlamp Glare&rdquo], p. 1 (&ldquoIt is almost always the case that headlamp glare reduces visual performance under driving conditions relative to the level of performance achievable without glare.&rdquo).

3. &thinspJohn D. Bullough et al. 2008. Nighttime Glare and Driving Performance: Research Findings, DOT HS 811 043. Washington, DC: U.S. Department of Transportation, National Highway Traffic Safety Administration, p. I-4.

4. &thinspId., p. 33. But see Investigation of Headlamp Glare, p. 3 (&ldquoVery few studies have probed the interactions between discomfort and disability glare, or indeed any driving-performance related factors . . . .&rdquo).

5. &thinsp2007 Report to Congress, p. iv.

8. &thinspThe upper beam photometric requirements are set out in Table XVIII the lower beam photometric requirements are set out in Table XIX.

9. &thinspThe Society of Automotive Engineers (now SAE International). SAE is an organization that develops technical standards based on best practices.

10. &thinspSee 54 FR 20066 (May 9, 1989) (explaining history of photometric requirements).

11. &thinsp43 FR 32416 (July 27, 1978).

12. &thinsp58 FR 3856 (Jan. 12, 1993).

13. &thinsp50 FR 42735 (Oct. 22, 1985) (Request for Comments).

14. &thinsp52 FR 30393 (Aug. 14, 1987) (Request for Comments).

15. &thinsp54 FR 20084 (May 9, 1989).

16. &thinspSee generally 66 FR 49594, 49596 (Sept. 28, 2001).

20. &thinspSafe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users, Public Law 109-59, Sec. 2015 (2005).

21. &thinspPerel & Singh. 2004. Drivers' Perceptions of Headlamp Glare from Oncoming and Following Vehicles, DOT HS 809 669. Washington, DC: National Highway Traffic Safety Administration.

22. &thinsp68 FR 7101 (Feb. 12, 2003) 70 FR 40974 (July 15, 2005) (withdrawn).

24. &thinspSee generally Summary of Headlamp Research at NHTSA, DOT HS 811 006. Washington, DC: National Highway Traffic Safety Administration (2008).

25. &thinspMichael J. Flannagan & John M. Sullivan. 2011. Feasibility of New Approaches for the Regulation of Motor Vehicle Lighting Performance. Washington, DC: National Highway Traffic Safety Administration. See also 77 FR 40843 (July 11, 2012) (request for comments on the report).

26. &thinspElizabeth Mazzae, G.H. Scott Baldwin, Adam Andrella, & Larry A. Smith. 2015. Adaptive Driving Beam Headlighting System Glare Assessment, DOT HS 812 174. Washington, DC: National Highway Traffic Safety Administration.

27. &thinspSAE J3069 JUN2016, Sec. 3.1.

28. &thinspSAE J3069JUN 2016, pp. 1-2.

30. &thinspJohn D. Bullough, Nicholas P. Skinner, Yukio Akashi, & John Van Derlofske. 2008. Investigation of Safety-Based Advanced Forward-Lighting Concepts to Reduce Glare, DOT HS 811 033. Washington, DC: National Highway Traffic Safety Administration, p. 63. See also, e.g., Mary Lynn Mefford, Michael J. Flannagan & Scott E. Bogard. 2006. Real-World Use of High-Beam Headlamps, UMTRI-2006-11. University of Michigan, Transportation Research Institute, p. 6 (finding that &ldquohigh-beam headlamp use is low . . . consistent with previous studies that used different methods&rdquo).

31. &thinspInvestigation of Safety-Based Advanced Forward-Lighting Concepts to Reduce Glare, DOT HS 811 033, p. 63.

32. &thinspMichael J. Flannagan & John M. Sullivan. 2011. Preliminary Assessment of The Potential Benefits of Adaptive Driving Beams, UMTRI-2011-37. University of Michigan, Transportation Research Institute, p. 2.

33. &thinsp2007 Report to Congress, p. 6. A recent study by the Insurance Institute for Highway Safety noted that &ldquo[t]wenty-nine percent of all fatalities during 2014 occurred in the dark on unlit roads. Although factors such as alcohol impairment and fatigue contributed to many of these crashes, poor visibility likely also played a role.&rdquo Ian J. Reagan, Matthew L. Brumbelow & Michael J. Flannagan. 2016. The Effects of Rurality, Proximity of Other Traffic, and Roadway Curvature on High Beam Headlamp Use Rates. Insurance Institute for Highway Safety, pp. 2-3 (citations omitted). See also Feasibility Study, p. 5 (&ldquoThe conclusion of our analysis was that pedestrian crashes were by far the most prevalent type of crash that could in principle be addressed by headlighting.&rdquo). See Appendix A for an analysis that roughly estimates the target population that could benefit from ADB technology.

34. &thinspLetter from Thomas Zorn, Volkswagen Group of America to Dr. Mark Rosekind, Administrator, NHTSA, Petition for Temporary Exemption from FMVSS 108 (October 10, 2016), pp. 1, 7.

35. &thinspSee, e.g., SAE J3069 (&ldquoHowever, in the United States it is unclear how ADB would be treated under the current Federal Motor Vehicle Safety Standard (FMVSS) 108.&rdquo).

36. &thinspLetter from Tom Stricker, Toyota Motor North America, Inc. to David Strickland (Mar. 29, 2013).

37. &thinspRegulation 48 defines AFS as &ldquoa lighting device type-approved according to Regulation No. 123, providing beams with differing characteristics for automatic adaptation to varying conditions of use of the dipped-beam (passing-beam) and, if it applies, the main-beam (driving-beam).&rdquo

38. &thinspSee Annex 12 to ECE R48.

39. &thinspMore specifically, they regulate glare that comes directly from the headlamps (as opposed to headlamp glare that reflects off of, say, the road surface).

40. &thinsp1U, 1.5L to L (700 cd maximum) 0.5U, 1.5L to L (1,000 cd maximum).

41. &thinsp1.5U, 1R to R (1,400 cd maximum) 0.5U, 1R to 3R (2,700 cd maximum).

42. &thinspCandela is a unit of measurement of luminous intensity. Candela is a measure of the amount of light coming from a source per unit solid angle.

43. &thinspIlluminance is the amount of light falling on a surface. The unit of measurement for illuminance is lux. Lux is a unit measurement of illuminance describing the amount of light falling on a surface, whereas candela is a measure of the luminous intensity produced by a light source in a particular direction per solid angle. A measure of luminous intensity in candela can be converted to a lux equivalent, given a specified distance.

44. &thinspA photometer, or illuminance meter, is an instrument that measures light.

45. &thinspThe motorcycle was not fitted with photometers because of time constraints and equipment availability. Illuminance receptors were located on a vehicle positioned adjacent to the motorcycle this vehicle's lamps remained off to ensure that the ADB-equipped vehicle was responding only to the motorcycle's lamps.

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